Voluntary Disclosure controls have begun and we can see dissimilar treatments.
Specialist fiscal Press says, for this reason, that has been released an internal directive by he Revenue Agency in order to have uniform conducts for the management of withdrawals.
As the Voluntary Disclosure is a substitute statement on the completeness and veracity of the acts committed with specific offense in case of falsehood, the internal document of the Revenue Agency reminds that the taxpayer is forced to tell the truth.
Considering also that:
• the presumption of profitability, relative to withdrawals (art. 32 DPR 600/73), is not applicable to individuals, professionals (Constitutional Court 228/14) and shareholders holding shares in non-enterprise regime
• the challenge of further activities (than those Taxpayer highlighted) must be proven by the Revenue Agency
the office must, in assessing cash withdrawals, consider several factors including the standard of living and the amount of declared income
This means, according to the internal directive, that the office may ask for an explanation of withdrawals but considering that:
• clarifications can not relate to insignificant amounts (as a comparison considering the declarations and the standard of living)
• Withdraw never involves income to the above cases
so we hope that all departments follow these guidelines.